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442, the requesting spouse was told by her husband to sign their
joint tax returns, and he controlled the couple’s finances and
was evasive and deceitful with respect to those finances. In
Price v. Commissioner, supra, the requesting spouse reviewed her
joint return, spotted the disputed deductions, and questioned her
husband about them. The husband misled the requesting spouse on
the validity of the deductions. In Laird v. Commissioner, supra,
the requesting spouse asked her husband about his tax shelter
programs but was ordered by him without any explanation to sign
their joint returns. The husband also coerced and intimidated
the requesting spouse both physically and mentally. In Estate of
Killian v. Commissioner, supra, the requesting spouse reviewed
her joint return, spotted an $11,756 claimed refund, and
questioned her husband about it. The husband misled the
requesting spouse as to the source of the refund.
We conclude that petitioner had “reason to know” of each
understatement at hand within the meaning of section
6015(b)(1)(C) when she signed those returns. Accordingly, we
hold that petitioner is not entitled to full/apportioned relief
for any of the subject years.
2. Proportionate Relief
Section 6015(c) allows a qualifying individual who has filed
a joint return to receive proportionate relief from the joint
liability that would otherwise relate to that return. In order
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